Court of Appeal of Zambia - 2024

348 judgments
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Results. 348 judgments found.

348 judgments
February 2024
Cancellation of a title over boundary uncertainty requires Surveyor‑General verification, not immediate cancellation.
  • Land registration — Certificate of Title — Boundary dispute vs. erroneous inclusion; Land Survey Act — role of Surveyor-General; proper remedy is re-survey and verification, not immediate cancellation of title; joinder of State via Attorney‑General for survey.
28 February 2024
Whether an unsigned sketch plan and oral evidence may vary a written memorandum of sale concerning land boundaries.
  • Property law — dispute over apportionment of land — Statute of Frauds — memorandum of sale — admissibility of extrinsic/parol evidence and unsigned sketch plan — boundaries and rectification — appellate review of credibility findings.
28 February 2024
A failed provocation/self-defence claim does not justify extenuation absent evidence of provocation; conviction and death sentence upheld.
  • Criminal law — Murder — Provocation and self-defence — Failed defence as extenuation — Requirements: provocative act, loss of self-control, proportionate retaliation — Malice aforethought — Sentencing — Extenuating circumstances.
27 February 2024
Appeal dismissed; eyewitness evidence and extra‑judicial confession rendered circumstantial case cogent, alibi rejected, conviction and death sentence upheld.
  • Criminal law — murder — circumstantial evidence and proof beyond reasonable doubt — eyewitness credibility — extra‑judicial confession admissibility — suspect/ interested witnesses — alibi — sentence (death).
27 February 2024
A weapon adaptable to discharge is a 'firearm' even if its trigger mechanism is defective.
  • Armed aggravated robbery; definition of "firearm" under Firearms Act; capacity to discharge or adaptability to discharge; role of ballistics/test-firing evidence; appellate review of factual findings.
24 February 2024
Appellate court upheld earlier title, found no proven fraud, and cancelled overlapping title No. 982.
  • Land law — Priority of title — Certificate of title conclusive under s.33 Lands and Deeds Registry Act — Fraud must be pleaded with particulars and strictly proved — Duty of due diligence by purchasers — Local authority as agent; Commissioner of Lands controls allocation — Injunctions and balance of convenience — Cancellation of overlapping title.
23 February 2024
Circumstantial evidence that the appellant assaulted the victim warranted murder conviction; appeal dismissed.
  • Criminal law — Murder — Circumstantial evidence — Causation — Novus actus interveniens — Credibility findings — Appeal against conviction
23 February 2024
A voluntary confession to a civilian, combined with cogent circumstantial evidence, can sustain a murder conviction.
  • Confession to a civilian — admissibility and voluntariness; exclusion only if unfairly obtained; circumstantial evidence — strands considered cumulatively; last-seen, possession of victim's property, scene links; investigative omissions do not necessarily render circumstantial case speculative.
23 February 2024
Court upheld murder convictions, holding relatives' eyewitness evidence need not be corroborated absent record evidence of bias.
  • Criminal law — murder — eyewitness evidence given by relatives of deceased — corroboration required only where record indicates bias, interest or motive to falsely implicate — appellate deference to trial court credibility findings — alibi rejected — appeal dismissed.
23 February 2024
Court set aside murder conviction after trial judge ignored crucial medical opinion, substituting a lesser assault conviction and sentence.
  • Criminal law — causation in homicide — weight and consideration of expert medical opinion — novus actus interveniens — appellate substitution to lesser offence (assault occasioning actual bodily harm).
23 February 2024
Whether a will’s clause makes the spouse trustee of pension benefits for minor children, otherwise vesting them in the residuary estate.
  • Wills — Testamentary construction — Appointment of spouse as trustee limited to WHO pension benefits for minor children; absence of minors or predeceased trustee causes benefits to vest in residuary estate; extraneous pension regulations not admissible as new evidence.
23 February 2024
Restoration of a dismissed appeal denied where counsel's absence lacked satisfactory explanation despite alleged registry misinformation.
  • Civil procedure — Restoration of dismissed appeal — Order X Rule 19(2) — Absence of counsel — Alleged registry misinformation — Requirement to prove sufficient reasons.
23 February 2024
Voice recognition corroborated by surrounding facts proved guilt; failure to investigate alibi was outweighed by strong evidence, no extenuation.
  • Criminal law — identification evidence by voice recognition — corroboration by surrounding circumstances; Alleged prosecutorial dereliction in failing to investigate alibi — prejudice and when strong evidence rebuts it; Extenuating circumstances — burden and absence of mitigating facts.
23 February 2024
Appeal dismissed for want of jurisdiction due to appellant's failure to file the record of appeal within prescribed time.
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23 February 2024
The Court held the departures were consensual voluntary separations, not redundancy, and dismissed the appeal.
  • Employment law — voluntary separation vs redundancy — unilateral variation of basic conditions of service — consent and participation — payroll retention and Article 189(2) — adequacy of trial court's reasons.
21 February 2024
Trial court erred by admitting unsworn child evidence and unconsented spouse testimony; conviction set aside.
  • Criminal law — Evidence of child witnesses — Juveniles Act s122 requires two-tier test (intelligence and understanding duty to tell truth) for oath; unsworn evidence improper where test not satisfied. Criminal procedure — Competency of spouse to testify — Criminal Procedure Code s151 exceptions required; spouse’s testimony inadmissible without accused’s consent if exceptions not met. Sexual offences — Corroboration and identity — where key witness evidence is expunged, conviction cannot stand; retrial discretionary and not ordered where remaining evidence insufficient
20 February 2024
Failure to address an appellant's guilty plea and make a pronouncement prejudiced trial; post-event taunting is not aiding and abetting.
  • Criminal procedure — Plea of guilty — necessity to read statement of facts and make pronouncement at close of prosecution — failure amounts to procedural irregularity and prejudice; Evidence — absence of exhibit does not preclude conviction where credible oral testimony proves disputed fact; Criminal liability — Section 21 aiding and abetting requires assistance before or during the offence — post-offence taunting is not aiding/abetting.
20 February 2024
Conviction based on uncorroborated identification by a suspect witness is unsafe and quashed.
  • Criminal law — Identification evidence — Suspect witness (detained in connection with offence) — Requirement of corroboration or "something more" — Failure to pursue phone records as investigative lapse — Conviction unsafe and quashed.
20 February 2024
Failure to investigate an alibi did not overturn conviction where credible daylight eyewitness identification offset the prejudice.
  • Criminal law — alibi — duty of police to investigate alibi; onus to disprove alibi — prosecution may rely on cogent identification evidence to offset investigative lapses; extenuating circumstances — grave and sudden provocation — belief in witchcraft not automatically exculpatory.
20 February 2024
Respondent lacked legal authority to levy takeover authorisation fee because the former Securities Act provided no basis for it.
  • Securities law — applicability of former versus current Securities Act — delegated legislation and statutory instruments — scope of fees under Rule 11 and Third Schedule — lawfulness of takeover authorisation fee — retroactivity and interpretation of enabling provisions.
18 February 2024
Loan fully disbursed; default occurred before COVID‑19; BFSA s110 limits interest on non‑performing loans; assessment ordered.
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16 February 2024
Delay beyond one year does not oust jurisdiction, but inadequate written reasons and improper costs warrant retrial before another judge.
  • Industrial relations — delay in judgment — one-year rule not jurisdictional (purposive interpretation); judgment writing — necessity of evidential review, findings and reasons; costs in industrial matters — generally not awarded except under Rule 44.
15 February 2024
A subsisting judicial separation excludes the spouse from intestate succession; minor dependant's entitlement upheld; administration orders clarified.
  • Matrimonial Causes Act — effect of a decree of judicial separation on intestate succession — Section 36(1) construed to exclude the separated spouse from intestacy; Intestate Succession — entitlement of dependants — minor recognised as dependant; Administration of estates — appointment of administrators requires assessment of suitability and legal interest; Procedural fairness — unclear revocation order and late filings; Costs — each party to bear own costs.
15 February 2024
The appellant acquiesced to rent increases and failed to seek court determination; arrears, possession and distraint orders were upheld.
  • Rent Act — standard rent — determination of standard rent — tenant’s acquiescence to rent increase — periodic tenancy — recovery of possession — warrant of distress — appellate review of factual findings — new issues not pleaded on appeal.
14 February 2024
Unpleaded issues cannot be raised on appeal; nominal damages vindicate a technical invasion of rights; costs follow the event.
  • Civil procedure — Pleadings and appeals: unpleaded issues cannot be raised for the first time on appeal; Sale of Goods Act (disposition of goods) — issue not pleaded; Tort — trespass/injuria; Nominal damages — appropriate where legal right infringed but no proven loss; Costs — discretionary, normally follow the event.
12 February 2024
An order awarding relief contrary to the court's own findings is a nullity and may be set aside on appeal.
  • Civil procedure — Judgment inconsistent with findings — Perverse order amounting to nullity — Appellate intervention; Writ of Fieri Facias set aside; principle that court orders must be obeyed until set aside.
12 February 2024
A company in liquidation may sue a former liquidator and third parties for misfeasance; section 117 is permissive and section 70(6) gives a statutory remedy.
  • Corporate insolvency — Liquidator misconduct and misfeasance — Competence of company in liquidation to sue — Section 117 (permissive) — Section 70(6) (personal liability for excess remuneration) — Stay of winding-up proceedings — Fresh action vs relief in winding-up.
9 February 2024
A company in liquidation may sue its former liquidator and a third party for misfeasance and statutory reimbursement despite a stayed winding-up.
  • Corporate insolvency — competence of company in liquidation to sue for misfeasance by liquidator; section 117 (court review of liquidator acts) is permissive — not an exclusive remedy; statutory liability under s.70(6) for excess remuneration; fresh action permissible where winding-up stayed; joinder and liability of third-party recipients of company funds.
9 February 2024
Resignation does not attract constitutional payroll retention; gratuity limited to contractual/pro rata entitlement and discrimination was unproven.
  • Constitutional law — Article 189 payroll retention applies to pension benefits under pension law, not contractual gratuity following resignation; Employment law — gratuity payable per contractual terms and Employment Code Act s73(2) (pro rata); Civil evidence — burden of proof on claimant asserting discrimination; Estoppel not established.
7 February 2024
Leave to appeal denied: succession-related customary law issues did not raise a public law point or prospects of success.
  • Court of Appeal — leave to appeal to Supreme Court — s.13(3)(a),(c),(d) Court of Appeal Act — point of law of public importance — customary law and chieftaincy succession — prospects of success — finality of litigation.
7 February 2024
January 2024
Appellant failed to prove fraud; third‑party mortgage valid, permitting foreclosure and enforcement of the personal guarantee.
  • Mortgage law — third‑party mortgage validity — allegation of forgery/fraud — standard of proof for fraud in civil cases — signature comparison and handwriting evidence — foreclosure and enforcement of personal guarantee.
31 January 2024
Costs ordinarily follow the event; interchangeable terminology did not justify denying the successful party costs.
  • Civil procedure — Costs — Judicial discretion — Costs ordinarily follow the event — Successful party may be deprived of costs only for good reason — Pleading terminology ("terminal benefits" vs "long service bonus") not improper conduct — Judgment on admission.
31 January 2024
Court refused late cross-appeal applications for insufficient, unsubstantiated reasons and procedural noncompliance.
  • Civil procedure — extension of time to file cross-appeal — Order 13 Rule 3(3) CAR — sufficiency of reasons — compliance with time limits — conflict of interest — abuse of process.
30 January 2024
Irrelevant proceedings in the record were expunged; late service was curable, leave granted, and costs ordered against the appellant.
  • Court of Appeal Rules (Order X Rule 9) — Record of appeal must contain only materials necessary for determination; extraneous proceedings curable by expunction. Service of record and heads outside 14‑day period — regulatory breach not necessarily fatal; court may grant leave to serve out of time. Procedural non‑compliance — dismissal only where defect is incurable or causes prejudice. Costs ordered against appellant
30 January 2024
Appeal dismissed for failure to file record within time; belated extension application without sufficient explanation was rejected.
  • Civil procedure — appeals — dismissal for want of prosecution — failure to file record of appeal within 60 days — reactive application for extension of time insufficient without good and convincing explanation — proof of service of requests for record — Article 118 (avoidance of technicalities) not a licence to flout procedural rules.
26 January 2024
A court granted the applicant's stay of execution pending appeal due to arguable prospects and risk of irreparable harm.
  • Civil procedure — Stay of execution pending appeal — Renewal application competency — Test: prospects of success and irreparable harm — Real property risk of foreclosure.
26 January 2024
Appeal dismissed: confession to relatives upheld as credible; foreign postmortem expunged for lack of author’s evidence.
  • Criminal law — Extra‑judicial confession to relatives — Admissibility and reliability; Postmortem report from foreign jurisdiction inadmissible without author giving evidence (s.191A CPC); Alibi not disclosed to police — no duty to investigate; Confession may ground conviction without corroboration where credible.
26 January 2024
Employee entitled to prior contractual redundancy rate, but not to continued wages during litigation.
  • Employment law — redundancy — preservation of pre-acquisition contractual terms — calculation of redundancy entitlement (five months per year) — remedy for underpaid terminal benefits — limitation on awarding salaries during litigation (reliance on Mcqueen Zenzo Zaza v ZESCO).
25 January 2024
Appeal dismissed: no proven contract with respondent and no vicarious liability for employee's unauthorised acts.
  • Contract formation — requirement of agreement and proof; Agency and authority — unauthorised acts and employee acting on a private job; Vicarious liability — employer not liable where employee acted outside authority; Turquand rule — exceptions where transaction appears suspicious; Appellate review — deference to trial findings of fact.
25 January 2024
Whether quarry blasting caused respondents' property damage and whether the trial court correctly found causation on the balance of probabilities.
  • Environmental/tort — quarry blasting and property damage — causation on balance of probabilities — weight of expert evidence — appellate interference with trial findings of fact.
25 January 2024
Confession to a village headman is admissible; police confession narrated by civilians was excluded, but conviction for aiding and abetting upheld.
  • Criminal law — admissibility of confession — village headman not a 'person in authority' requiring warn-and-caution; police confessions must comply with Judges' Rules — evidence of mere presence versus aiding and abetting under section 21 of the Penal Code.
25 January 2024
Bank liable where it failed to follow verification procedures for over‑the‑counter withdrawals, despite payments claimed to be in good faith.
  • Banking law — duty of care to customers — payment on forged/unauthorised withdrawal slips — verification procedures; estoppel — requirement of evidence of reliance and prejudice; discretionary closure of trial and refusal of further adjournment; third‑party proceedings — failure to prosecute.
24 January 2024
Appellate court upheld trial finding of US$907,900 indebtedness, set aside remittal for assessment and ordered direct payment.
  • Contract and evidence — acknowledgement of debt — sufficiency and corroboration; burden of proof in civil cases; appellate review of findings of fact — perverse/unwarranted interference; procedural non-compliance — substantive consideration in interest of justice; remittal for assessment vs. direct award.
19 January 2024
Ambiguous age report required juvenile consideration; death sentence set aside and replaced with one-year probation.
  • Criminal law — murder sentencing — age determination ambiguity — possible juvenile status — misdirection by sentencing without pronouncing on age — death sentence set aside; substituted one-year probation under Probation of Offenders Act and Children's Code.
19 January 2024
Application for stay of execution dismissed for lack of prospects and because the Ruling sought to be stayed was not subject to appeal.
  • Civil procedure — stay of execution pending appeal — discretionary remedy — applicant must show good and cogent reasons and prospects of success; court entitled to preview appeal prospects; stay ordinarily requires an appeal pending and will not be granted in respect of a ruling not appealed.
19 January 2024
16 January 2024
A conditional leave to appeal imposed where no statutory leave was required is void; appeal competent, but appellant ordered to pay costs.
  • Civil procedure — Appeal jurisdiction — Right of appeal under s.22 Court of Appeal Act — Conditional leave to appeal — Void ab initio — Compliance with court orders pending vacation or variation — Costs for disobedience of order.
15 January 2024
Conditional leave to appeal imposed where no leave was required was void ab initio; appeal competent but appellant ordered to pay costs.
  • Civil appeal — final judgment — right of appeal under s.22 Court of Appeal Act — conditional leave requiring payment into court — ultra vires; nullity — effect of void orders (Macfoy) — duty to obey court orders until set aside (Majera) — conditional leave to be sparingly used — costs for disobedience of court orders.
15 January 2024